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Articles Tagged with: Climate Risk

Webinar: Geocoding Mortgage Data for ESG and Climate Risk Analysis

Recorded: February 16th | 1:00 p.m. ET

Geocoding remains a particularly vexing challenge for the mortgage industry. Lenders, servicers, and loan/MSR investors know the addresses of the properties securing their mortgage assets. But most data pertaining to climate and other ESG considerations is available only by matching to a census tract or latitude/longitude.

And if you have ever tried mapping addresses, you know this exercise can be a lot harder than it looks. Fortunately, a growing body of geocoding tools and techniques is emerging to make the process more manageable than ever, even with less than perfect address data.

Our panel presents a how-to guide on geocoding logic and its specific application to the mortgage space. You will learn a useful waterfall approach for linking census-tract-level, geo-specific data for climate risk and ESG to the property addresses in your portfolio.

 

Featured Speakers

Suhrud Dagli

Chief Innovation Officer, RiskSpan

Jason Huang

Manager, RiskSpan

Jason Lee

Software Engineer, RiskSpan


How Has the First “Social” RMBS Performed – And What’s So Social About It?

Now that six months have passed since Angel Oak issued AOMT 2021-2 – hailed as the first U.S. non-Agency RMBS to qualify as a social bond [1] – we can compare preliminary collateral performance to other deals. Angel Oak’s 2021-1, from the same shelf and vintage – but without the social bond distinction – provides an apt control group. To set the stage for this performance comparison, we’ll first reexamine the compositional differences – and significant overlap – between the two collateral pools. What we will show:

  • The pool compositions are highly overlapping, with marginally greater risk concentrations of self-employment and alternative documentation in the social securitization, and the same WA (weighted average) coupon
  • The social collateral has outperformed the benchmark credit-wise in the early going
  • The social deal has exhibited some lock-in, i.e., slower refinancing, providing some very preliminary evidence that the borrowers are indeed underserved, and that investors may be rewarded if the social collateral’s credit performance holds
  • However, the credit mix of the social collateral has drifted riskier – more so than the benchmark – meaning the strong early credit performance of the social deal could reverse, and ongoing surveillance is warranted

New Loans or New Label?


The Social AOMT 2021-2 Is Similar to AOMT 2021-1

Figure 1 shows AOMT 2021-1 vs. 2021-2 in the Collateral Comparison screen of Edge, RiskSpan’s data and analytics platform. Clearly, the two pools were similar at origination, with highly overlapping distributions of FICO, LTV, and DTI and many other similar metrics.

So What’s Different – And How Different Is It?

The distinguishing principle of a social bond under Angel Oak’s framework is that it provides affordable home mortgages to those who often can’t get them because they don’t qualify under the automated underwriting processes of traditional lenders because of the exceptional nature of their sources of income. [2]

Angel Oak says the specific characteristic hindering the borrowers in the AOMT 2021-2 deal is self-employment. [3] Self-employed borrowers make up 94.4% of the pool (with a median annual income of $227,803) [4], up marginally from 86.5% in the 2021-1 deal [5]. As Figure 1 shows, the proportion of low documentation by balance was up from 87.5% in 2021-1 to 97.5% in 2021-2.

Also, Figure 1 shows that 2021-2’s FICOs and LTVs are slightly worse on average with slightly more tail risk, and the cash-out proportion is slightly riskier.

Compensating marginally for 2021-2 are slightly lower ARM proportions (0 vs. 0.8% for 2021-1), lower WA. DTI, and a higher proportion of owner-occupied (90% vs. 85%), which many view as credit-positive.

In summary, RiskSpan calculates 1.83 average risk layers per loan for the social 2021-2, slightly higher than 1.78 for 2021-1.

Notably the WA coupons for the two pools are the same.


Figure 1: Edge’s Collateral Comparison Screen Showing AOMT 2021-1 (aka AOAK 2101) vs. 2021-2 (aka AOAK 2102) at OriginationGraphSource: CoreLogic, RiskSpan


Would you like to see the tool we used to perform this analysis?

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In summary, it seems that most – though perhaps not all – of the loans that qualified for AOMT 2021-2 would have qualified for AOMT 2021-1 and other non-QM deals.

Kroll’s new issue report seems to acknowledge that what is new about 2021-2 is mostly the formal emphasis on the social benefits of the loans made, and less a change in the kinds of loans made: “While many of [Angel Oak’s] lending programs overlap meaningfully with other non-QM lender’s offerings, the actions taken by AOCA generally indicate management’s attention to ESG related matters. Specifically, AOCA’s SBF puts focus on the impact that credit availability for underserved borrowers can have.” [4]

A skeptical interpretation of the overlap between 2021-1 and the social 2021-2 collateral would be that the social claim is largely hollow. Another way of looking at it is that a financial market participant is finally taking credit for good work it has been largely doing all along. Angel Oak itself seems to take this latter view, saying, “Since 2011, AOCA has been implementing ESG principles within its non-qualified mortgage (non-QM) origination and securitization program to provide access to residential credit for underserved borrowers.” [2]

Either way, logical hypotheses would be that collateral performance will be similar between 2021-2 and 2021-1, with -2 showing (a) slightly more credit trouble and (b) slightly less able to refinance. Regarding the second hypothesis, logically it should challenge the premise that the deal serves underserved borrowers if its borrowers can refinance just as readily as others.

Early Performance of the Social Bonds


Let’s see how AOMT’s social 2021-2 has performed as benchmarked to 2021-1 during the first six and seven months, respectively, of available data.

Better Delinquency Trend Than the Benchmark

As Figure 2 shows, delinquencies opened higher for the social 2021-2 but have mostly cured. By contrast, delinquencies have trended up for 2021-1. So far, Angel Oak’s social origination is outperforming its non-social contemporary from a credit standpoint.


Figure 2: AOMT 2021-2 Delinquencies Began Higher, Have Mostly Cured; AOMT 2021-1’s Delinquencies Have Trended Up 60 day-plus delinquency share over time, AOMT 2021-2 vs AOMT 2021-1 Source: CoreLogic, RiskSpan


Significantly Better Credit Performance by the Social DSCR Investor Loans

A small slice of the deals driving outsized delinquencies in 2021-1 are the DSCR-based investor loans (Figure 3). In the social 2021-2, delinquencies among this cohort are zero. We plot the spreads at origination (SATO) of this cohort alongside delinquencies to show that the DSCR loans in 2021-2 had lower credit spreads by about 20bps. Perhaps the investor loans pooled into 2021-2 were managed to higher standards for DSCR, rent rolls or other attributes (their LTVs and ages are similar).


Figure 3: Delinquencies – and SATOs – Are Lower Among DSCR-Based Investor Loans in AOMT 2021-2 60 day-plus delinquency share and WA SATOs over time, AOMT 2021-2 vs. AOMT 2021-1, includes Detailed Doc Type = DSCR Investor Cash Flow.Source: CoreLogic, RiskSpan


Ironically, The Full Doc Loans Are the Social Deal’s Blemish

The slice of full doc loans in the social 2021-2 have a much lower WA FICO than the low doc loans in the same deal or either the low or full doc loans in 2021-1 (see the green dotted line in Figure 4). Correspondingly, these full doc loans have the highest delinquent share among the four cohorts in Figure 4 (green solid line). If this pattern holds, it highlights the viability of using tradeoffs to manage down the overall credit risk represented by loans with risky attributes.


Figure 4: AOMT 2021-2’s Full Doc Loans Are the Most Delinquent Doc Cohort from Either Deal 60 day-plus delinquency share and WA FICOs over time, AOMT 2021-2 vs. AOMT 2021-1 and Full Doc vs. Low Doc Source: CoreLogic, RiskSpan


Slower Refinances Than the Benchmark

While credit performance has been better for the social deal than we might expect, voluntary prepays so far (Figure 5) support our hypothesis that the social deal should prepay slower. Note that we plot voluntary prepays over loan age, and that all loans from this recent non-QM vintage have similar (and highly positive) refinance incentive. If the social deal’s refinances remain slower, that accomplishes two significant things: 1) it supports the claim that the social borrowers are indeed underserved; 2) if combined with sustained credit performance, it provides support in terms of financial risk and return for the price premiums that social bonds tend to command.


Figure 5: AOMT 2021-2 Is Refinancing Slower CRR over loan age, AOMT 2021-2 vs. AOMT 2021-1, July 2021-January 2022 Source: CoreLogic, RiskSpan


The Relative Refinance Slowness Is From the Large Balance Loans

The overall slowness of the social collateral in Figure 5 is driven by large loans. Figure 6 shows that, among loans <$417K, the prepay patterns of 2021-1 and 2021-2 are similar, while among loans > $417K, the prepays of 2021-2 are consistently slower. This may suggest that large loans with complex sources of income are particularly hard to underwrite.


Figure 6: The Social Deal’s Low-Balance Loans Refi Similar to Benchmark, But Large Balances Have Been Slower CRR over loan age, AOMT 2021-2 vs. AOMT 2021-1, bucketed by loan size, July 2021-January 2022 Source: CoreLogic, RiskSpan


 

Updated Collateral Mix


The Social Deal’s Credit Mix Has Drifted Riskier, Warranting Ongoing Monitoring

While the early performance of the social collateral is positive, Figure 7 provides reason for concern and ongoing watchfulness. Since origination, the composition of the social 2021-2 has drifted riskier in all respects except slight improvements in WA DTI and WA LTV. Its LTV tails, WA FICO, and FICO tails; proportions of cash-out, low doc, non-owner-occupied; and average overall risk layers are all somewhat riskier.

The drift for 2021-1 has been more mixed. Like 2021-2, it is safer with respect to WA DTI and WA LTV. Unlike 2021-2, it is also safer with respect to LTV tails, FICO tails, and cash-out proportion. Like 2021-2, it is riskier with respect to WA FICO; proportions of low doc and non-owner-occupied; and average overall risk layers.

We will continue to monitor whether this composition drift drives differential performance going forward.


Figure 7: Edge’s Collateral Comparison Screen Showing AOMT 2021-1 (aka AOAK 2101) vs. 2021-2 (aka AOAK 2102) updated to the Current Factor DateGraphSource: CoreLogic, RiskSpan


Using Edge, you can examine prepay or credit performance of loan subsets defined by any characteristics, and generate aging curves, time series, or S-curves.

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Improving MSR Pricing Using Cloud-Based Loan-Level Analytics — Part II: Addressing Climate Risk

Modeling Climate Risk and Property Valuation Stability

Part I of this white paper seriesKey Takeaways introduced the case for why loan-level (as opposed to rep-line level) analytics are increasingly indispensable when it comes to effectively pricing an MSR portfolio. Rep-lines are an effective means for classifying loans across many important categories. But certain loan, borrower, and property characteristics simply cannot be “rolled up” to the rep-line level as easily as UPB, loan age, interest rate, LTV, credit score, and other factors. This is especially true when it comes to modeling based on available information about a mortgage’s subject property.

Assume for the sake of simplicity that human and automated appraisers do a perfect job of assigning property values for the purpose of computing origination and updated LTVs (they do not, of course, but let’s assume they do). Prudent MSR investors should be less interested in a property’s current value than in what is likely to happen to that value over the expected life of their investment. In other words, how stable is the valuation? How likely are property values within a given zip code, or neighborhood, or street to hold?

The stability of any given property’s value is tied to the macroeconomic prospects of its surrounding community. Historical and forecast trends of the local unemployment rate can be used as a rough proxy for this and are already built into existing credit and prepayment models. But increasingly, a second category of factors is emerging as an important predictor of home price stability, the property’s exposure to climate risk and natural hazard events.

Climate exposure is becoming increasingly difficult to ignore when it comes to property valuation. And accounting for it is more complicated than simply applying a premium to coastal properties. Climate risk is not just about hurricanes and storm surges anymore. A growing number of inland properties are being identified as at risk not just to wind and water hazards, but to wildfire and other perils as well. The diversity of climate risks means that the problem of quantifying and understanding them will not be solved simply by fixing out-of-date flood plain maps.

MSR investors are exposed to climate risk in ways that whole loan or securities investors are not. When climate events force borrowers into forbearance or other repayment plans, MSR investors not only forego the cash flows associated with missed interest payments that will never be made, but also incur the additional costs of administering the loss mitigation programs and making necessary P&I and escrow advances.

Overlaying climate scenario analysis on top of traditional credit modeling is unquestionably the future of quantifying mortgage asset exposure. And in many respects, the future is already here. Regulatory guidance is forthcoming requiring public companies to quantify their exposure to climate risk across three categories: acute physical risk, chronic physical risk, and economic transition risk.

Acute Risk

Acute climate risk describes a property’s exposure to individual catastrophic events. As a result of climate change, these events are expected to increase in frequency and severity. The property insurance space already has analytical tools in place to quantify property damage to hazard risks such as:

  • Hurricane, including wind, storm surge, and precipitation-induced flooding
  • Flooding, including “fluvial” and “pluvial” – on- and off-plan flooding
  • Wildfire
  • Severe thunderstorm, including exposure to tornadoes, hail, and straight-line wind, and
  • Earthquake – though not tied to climate change, earthquakes remain a massively underinsured risk that can impact MSR holders

Acute risks are of particular concern for MSR holders as disaster events have proven to increase both mortgage delinquency and prepayment. The chart below illustrates these impacts after hurricane Katrina.

Chronic Risk

Chronic risk characterizes a property’s exposure to adverse conditions brought on by longer-term concerns. These include frequent flooding, sea level rise, drought hazards, heat stress, and water shortages. These effects could erode home values or put entire communities at risk over a longer period. Models currently in use forecast these risks over 20- and 25-year periods.

Transition Risk

Transition risk describes exposure to changing policies, practices or technologies that arise from a broader societal move to reduce its carbon footprint. These include increases in the direct cost of homeownership (e.g., taxes, insurance, code compliance, etc.), increased energy and other utility costs, and localized employment shocks as businesses and industry leave high-risk areas. Changing property insurance requirements (by the GSEs, for example) could further impact property valuations in affected neighborhoods.

———–

Converting acute, chronic and transition risks into mortgage modeling scenarios can only be done effectively at the loan level. Rep-lines cannot adequately capture them. As with most prepayment and credit modeling, accounting for climate risk is an exercise in scenario analysis. Building realistic scenarios involves taking several factors into account.

Scenario Analysis

Quantifying physical risks (whether acute or chronic) entails identifying:

  • Which physical hazard types the property is exposed to
  • How each hazard type threatens the property[1]
  • The materiality of each hazard; and
  • The most likely timeframes over which these hazards could manifest

Factoring climate risk into MSR pricing requires translating the answers to the questions above into mortgage modeling scenarios that function as credit and prepayment model inputs. The following table is an example of how RiskSpan overlays the impact of an acute event – specifically a category 5 hurricane in South Florida — on home price, delinquency, turnover and macroeconomic conditions.

 

Chart

 

Chart

Applying this framework to an MSR portfolio requires integration with an MSR cash flow engine. MSR cash flows and the resulting valuation are driven by the manner in which the underlying delinquency and prepayment models are affected. However, at least two other factors affect servicing cash flows beyond simply the probability of the asset remaining on the books. Both of these are likely impacted by climate risk.

  • Servicing Costs: Rising delinquency rates are always accompanied by corresponding increases in the cost of servicing. An example of the extent to which delinquencies can affect servicing costs was presented in our previous paper. MSR pricing models take this into account by applying a different cost of servicing to delinquent loans. Some believe, however, that servicing loans that enter delinquency in response to a natural disaster can be even more expensive (all else equal) than servicing a loan that enters delinquency for other reasons. Reasons for this range from the inherent difficulty of reaching displaced persons to the layering impact of multiple hardships such events tend to bring upon households at once.[2]
  • Recapture Rate: The data show that prepayment rates consistently spike in the wake of natural disasters. What is less clear is whether there is a meaningful difference in the recapture rate for these prepayments. Anecdotally, recapture appears lower in the case of natural disaster, but we do not have concrete data on which to base assumptions. This is clearly only relevant to MSR investors that also have an origination arm with which to capture loans that refinance.

Climate risk encompasses a wide range of perils, each of which affects MSR values in a unique way. Hurricanes, wildfires, and droughts differ not only in their geography but in the specific type of risk they pose to individual properties. Even if there were a way of assigning every property in an MSR portfolio a one-size-fits-all quantitative score, computing a “weighted average climate risk” value and applying it to a rep-line would be problematic. Such an average would be denuded of any nuance specific to individual perils. Peril-specific data is critical to being able to make the LTV, delinquency, turnover and macroeconomic assumption adjustments outlined above.

And there is no way around it. Doing all this requires a loan-by-loan analysis. RiskSpan’s Edge Platform was purpose built to analyze mortgage portfolios at the loan level and is becoming the industry’s go-to solution for measuring and managing exposures to market, credit and climate events.

Contact us to learn more.


[1] Insurability of hazards varies widely, even before insurance requirements are considered.

[2] In addition, because servicers normally staff for business-as-usual levels of delinquencies, a large acute event will create a significant spike in the demand for servicer personnel. If a servicer’s book is heavily concentrated in the Southeast, for example, a devastating storm could result in having to triple the number of people actively servicing the portfolio.


An Emerging Climate Risk Consensus for Mortgages?

That climate change poses a growing—and largely unmeasured—risk to housing and mortgage investors is not news. As is often the case with looming threats whose timing and magnitude are only vaguely understood, increased natural hazard risks have most often been discussed anecdotally and in broad generalities. This, however, is beginning to change as the reality of these risks becomes increasingly clear to an increasing number of market participants and industry-sponsored research begins to emerge.

This past week’s special report by the Mortgage Bankers Association’s Research Institute for Housing America, The Impact of Climate Change on Housing and Housing Finance, raises a number of red flags about our industry’s general lack of preparedness and the need for the mortgage industry to take climate risk seriously as a part of a holistic risk management framework. Clearly this cannot happen until appropriate risk scenarios are generated and introduced into credit and prepayment models.

One of the puzzles we are focusing on here at RiskSpan is an approach to creating climate risk stress testing that can be easily incorporated into existing mortgage modeling frameworks—at the loan level—using home price projections and other stress model inputs already in use. We are also partnering with firms who have been developing climate stress scenarios for insurance companies and other related industries to help ensure that the climate risk scenarios we create are consistent with the best and most recently scientific research available.

Also on the short-term horizon is the implementation of FEMA’s new NFIP premiums for Risk Rating 2.0. Phase I of this new framework will begin applying to all new policies issued on or after October 1, 2021. (Phase II kicks in next April.) We wrote about this change back in February when these changes were slated to take effect back in the spring. Political pressure, which delayed the original implementation may also impact the October date, of course. We’ll be keeping a close eye on this and are preparing to help our clients estimate the likely impact of FEMA’s new framework on mortgages (and the properties securing them) in their portfolios.

Finally, this past week’s SEC statement detailing the commission’s expectations for climate-related 10-K disclosures is also garnering significant (and warranted) attention. By reiterating existing guidelines around disclosing material risks and applying them specifically to climate change, the SEC is issuing an unmistakable warning shot at filing companies who fail to take climate risk seriously in their disclosures.

Contact us (or just email me directly if you prefer) to talk about how we are incorporating climate risk scenarios into our in-house credit and prepayment models and how we can help incorporate this into your existing risk management framework.  



Climate Terms the Housing Market Needs to Understand

The impacts of climate change on housing and holders of mortgage risk are very real and growing. As the frequency and severity of perils increases, so does the associated cost – estimated to have grown from $100B in 2000 to $450B 2020 (see chart below). Many of these costs are not covered by property insurance, leaving homeowners and potential mortgage investors holding the bag. Even after adjusting for inflation and appreciation, the loss to both investors and consumers is staggering. 

Properly understanding this data might require adding some new terms to your personal lexicon. As the housing market begins to get its arms around the impact of climate change to housing, here are a few terms you will want to incorporate into your vocabulary.

  1. Natural Hazard

In partnership with climate modeling experts, RiskSpan has identified 21 different natural hazards that impact housing in the U.S. These include familiar hazards such as floods and earthquakes, along with lesser-known perils, such as drought, extreme temperatures, and other hydrological perils including mudslides and coastal erosion. The housing industry is beginning to work through how best to identify and quantify exposure and incorporate the impact of perils into risk management practices more broadly. Legacy thinking and risk management would classify these risks as covered by property insurance with little to no downstream risk to investors. However, as the frequency and severity increase, it is becoming more evident that risks are not completely covered by property & casualty insurance.

We will address some of these “hidden risks” of climate to housing in a forthcoming post.

  1. Wildland Urban Interface

The U.S. Fire Administration defines Wildland Urban Interface as “the zone of transition between unoccupied land and human development. It is the line, area, or zone where structures and other human development meet or intermingle with undeveloped wildland or vegetative fuels.” An estimated 46 million residences in 70,000 communities in the United States are at risk for WUI fires. Wildfires in California garner most of the press attention. But fire risk to WUIs is not just a west coast problem — Florida, North Carolina and Pennsylvania are among the top five states at risk. Communities adjacent to and surrounded by wildland are at varying degrees of risk from wildfires and it is important to assess these risks properly. Many of these exposed homes do not have sufficient insurance coverage to cover for losses due to wildfire.

  1. National Flood Insurance Program (NFIP) and Special Flood Hazard Area (SFHA)

The National Flood Insurance Program provides flood insurance to property owners and is managed by the Federal Emergency Management Agency (FEMA). Anyone living in a participating NFIP community may purchase flood insurance. But those in specifically designated high-risk SFPAs must obtain flood insurance to obtain a government-backed mortgage. SFHAs as currently defined, however, are widely believed to be outdated and not fully inclusive of areas that face significant flood risk. Changes are coming to the NFIP (see our recent blog post on the topic) but these may not be sufficient to cover future flood losses.

  1. Transition Risk

Transition risk refers to risks resulting from changing policies, practices or technologies that arise from a societal move to reduce its carbon footprint. While the physical risks from climate change have been discussed for many years, transition risks are a relatively new category. In the housing space, policy changes could increase the direct cost of homeownership (e.g., taxes, insurance, code compliance, etc.), increase energy and other utility costs, or cause localized employment shocks (i.e., the energy industry in Houston). Policy changes by the GSEs related to property insurance requirements could have big impacts on affected neighborhoods.

  1. Physical Risk

In housing, physical risks include the risk of loss to physical property or loss of land or land use. The risk of property loss can be the result of a discrete catastrophic event (hurricane) or of sustained negative climate trends in a given area, such as rising temperatures that could make certain areas uninhabitable or undesirable for human housing. Both pose risks to investors and homeowners with the latter posing systemic risk to home values across entire communities.

  1. Livability Risk

We define livability risk as the risk of declining home prices due to the desirability of a neighborhood. Although no standard definition of “livability” exists, it is generally understood to be the extent to which a community provides safe and affordable access to quality education, healthcare, and transportation options. In addition to these measures, homeowners also take temperature and weather into account when choosing where to live. Finding a direct correlation between livability and home prices is challenging; however, an increased frequency of extreme weather events clearly poses a risk to long-term livability and home prices.

Data and toolsets designed explicitly to measure and monitor climate related risk and its impact on the housing market are developing rapidly. RiskSpan is at the forefront of developing these tools and is working to help mortgage credit investors better understand their exposure and assess the value at risk within their businesses.

Contact us to learn more.



Why Mortgage Climate Risk is Not Just for Coastal Investors

When it comes to climate concerns for the housing market, sea level rise and its impacts on coastal communities often get top billing. But this article in yesterday’s New York Times highlights one example of far-reaching impacts in places you might not suspect.

Chicago, built on a swamp and virtually surrounded by Lake Michigan, can tie its whole existence as a city to its control and management of water. But as the Times article explains, management of that water is becoming increasingly difficult as various dynamics related to climate change are creating increasingly large and unpredictable fluctuations in the level of the lake (higher highs and lower lows). These dynamics are threatening the city with more frequency and severe flooding.

The Times article connects water management issues to housing issues in two ways: the increasing frequency of basement flooding caused by sewer overflow and the battering buildings are taking from increased storm surge off the lake. Residents face increasing costs to mitigate their exposure and fear the potentially negative impact on home prices. As one resident puts it, “If you report [basement flooding] to the city, and word gets out, people fear it’s going to devalue their home.”

These concerns — increasing peril exposure and decreasing valuations — echo fears expressed in a growing number of seaside communities and offer further evidence that mortgage investors cannot bank on escaping climate risk merely by avoiding the coasts. Portfolios everywhere are going to need to begin incorporating climate risk into their analytics.



Hurricane Season a Double-Whammy for Mortgage Prepayments

As hurricane (and wildfire) season ramps up, don’t sleep on the increase in prepayment speeds after a natural disaster event. The increase in delinquencies might get top billing, but prepays also increase after events—especially for homes that were fully insured against the risk they experienced. For a mortgage servicer with concentrated geographic exposure to the event area, this can be a double-whammy impacting their balance sheet—delinquencies increase servicing advances, prepays rolling loans off the book. Hurricane Katrina loan performance is a classic example of this dynamic.

Hurrican-Season-a-Double-Whammy-for-Mortgage



In ESG Policy, ‘E’ Should Not Come at the Expense of ‘S’

ESG—it is the hottest topic in our space. No conference or webinar is complete without a panel touting the latest ESG bond or the latest advance in reporting and certification. What a lot of these pieces neglect to address is the complicated relationship between the “E” and the “S” of ESG. In particular, that climate-risk exposed properties are also often properties in underserved communities, providing much-needed affordable housing to the country.

Last week, the White House issued an Executive Order of Climate-Related Financial Risk. The focus of the order was to direct government agencies toward both disclosure and mitigation of climate-related financial risk. The order reinforces the already relentless focus on ESG initiatives within our industry. The order specifically calls on the USDA, HUD, and the VA to ‘consider approaches to better integrate climate-related financial risk into underwriting standards, loan terms and conditions, and asset management and servicing procedures, as related to their Federal lending policies and programs.” Changes here will likely presage changes by the GSEs.

In mortgage finance, some of the key considerations related to disclosure and mitigation are as follows:

Disclosure of Climate-Related Financial Risk:

  • Homes exposed to increasing occurrence to natural hazards due to climate changes.
  • Homes exposed to the risk of decreasing home prices due to climate change, because of either increasing property insurance costs (or un-insurability) or localized transition risks of industry-exposed areas (e.g., Houston to the oil and gas industry).

Mitigation of Climate-Related Financial Risk:

  • Reducing the housing industry’s contribution to greenhouse gas emissions in alignment with the president’s goal of a net-zero emissions economy by 2050. For example, loan programs that support retrofitting existing housing stock to reduce energy consumption.
  • Considering a building location’s exposure to climate-related physical risk. Directing investment away for areas exposed to the increasing frequency and severity of natural disasters.

But products and programs that aim to support the goal of increased disclosure and mitigation of climate-related financial risk can create situations in which underserved communities disproportionately bear the costs of our nation’s pivot toward climate resiliency. The table below connects the FEMA’s National Risk Index data to HUD’s list of census tracts that qualify for low-income housing tax credits, which HUD defines as tracts that have ‘50 percent of households with incomes below 60 percent of the Area Median Gross Income (AMGI) or have a poverty rate of 25 percent or more.’ Census tracts with the highest risk of annual loss from natural disaster events are disproportionally made of HUD’s Qualified Tracts.

As an industry, it’s important to remember that actions taken to mitigate exposure to increasing climate-related events will always have a cost to someone. These costs could be in the form of increased insurance premiums, decreasing home prices, or even loss of affordable housing options altogether. All this is not to say that action should not be taken, only that balancing social ESG goals should also be considered when ambitious environmental ESG goals come at their expense.

The White House identified this issue right at the top of the order by indicating that any action on the order would need to account for ‘disparate impacts on disadvantaged communities and communities of color.’

“It is therefore the policy of my Administration to advance consistent, clear, intelligible, comparable, and accurate disclosure of climate-related financial risk (consistent with Executive Order 13707 of September 15, 2015 (Using Behavioral Science Insights to Better Serve the American People), including both physical and transition risks; act to mitigate that risk and its drivers, while accounting for and addressing disparate impacts on disadvantaged communities and communities of color (consistent with Executive Order 13985 of January 20, 2021 (Advancing Racial Equity and Support for Underserved Communities Through the Federal Government)) and spurring the creation of well-paying jobs; and achieve our target of a net-zero emissions economy by no later than 2050.”

The social impacts of any environmental initiative need to be considered. Steps should be taken to avoid having the cost of changes to underwriting processes and credit policies be disproportionately borne by underserved and vulnerable communities. To this end, a balanced ESG policy will ultimately require input from stakeholders across the mortgage industry.


Flood Insurance Changes: What Mortgage Investors Need to Know

Major changes are coming to FEMA’s National Flood Insurance Program on April 1st2021, the impacts of which will reverberate throughout real estate, mortgage, and structured finance markets in a variety of ways. 

For years, the way the NFIP has managed flood insurance in the United States has been the subject of intense scrutiny and debateCompounding the underlying moral hazard issues raised by the fact that taxpayers are subsidizing homeowners who knowingly move into flood-prone areas is the reality that the insurance premiums paid by these homeowners collectively are nowhere near sufficient to cover the actual risks faced by properties in existing flood zones. 

Climate change is only exacerbating the gap between risk and premiums. According to research released this week by First Street Foundation, the true economic risk is 3.7 times higher than the level at which the NFIP is currently pricing flood insurance. And premiums would need to increase by 7 times to cover the expected economic risk in 2051. 

New York Times article this week addresses some of the challenges (political and otherwise) a sudden increase in flood insurance premiums would create. These include existing homeowners no longer being able to afford the higher monthly payments as well as a potential drop in property values in high-risk areas as the cost of appropriately priced flood insurance is priced in. These risks are also of concern to mortgage investors who obviously have little interest in seeing sudden declines in the value of properties that secure the mortgages they own. 

Notwithstanding these risks, the NFIP recognizes that the disparity between true risk and actual premiums cannot continue to go unaddressed. The resulting adjustment to the way in which the NFIP will calculate premiums – called Risk Rating 2.0  will reflect a policy of phasing out subsidies (wherein lower-risk dwellings absorb the cost of those in the highest-risk areas) and tying premiums to thactual flood risk of a given structure. 

Phase-In 

The specific changes to be announced on April 1st will go into effect on October 1st, 2021. But the resulting premium increases will not happen all at once. Annual limits currently restrict how fast premiums can increase for primary residences, ranging from 5%-18% per year. (Non-primary residences have a cap of 25%). FEMA has not provided much guidance on how these caps will apply under Risk Rating 2.0 other than to say that all properties will be on a glide path to actuarial rates.” The caps, however, are statutory and would require an act of Congress to change. And Members of Congress have shown reluctance in the past to saddle their constituents with premium spikes. 

Phasing in premium increases helps address the issue of affordability for current homeowners. This is equally important to investors who hold these existing homeowners’ mortgages. It does not however, address the specter of significant property value declines because the sale of the home has historically caused the new, fully priced premium to take effect for the next homeowner. It has been suggested that FEMA could blunt this problem by tying insurance premiums to properties rather than to homeowners. This would enable the annual limits on price increases to remain in effect even if the house is sold. 

Flood Zones & Premiums 

Despite a widely held belief that flood zone maps are out of date and that climate change is hastening the need to redraw them, Risk Rating 2.0 will reportedly apply only to homes located in floodplains as currently defined. Premium calculations, however, will focus on the geographical and structural features of a particular home, including foundation type and replacement cost, rather than on a property’s location within a flood zone.  

The Congressional Research Service’s paper detailing Risk Rating 2.0 acknowledges that premiums are likely to go up for many properties that are currently benefiting from subsidies. The paper emphasizes that it is not in FEMA’s authority to provide affordability programs and that this is a job for Congress as they consider changes to the NFIP. 

“FEMA does not currently have the authority to implement an affordability program, nor does FEMA’s current rate structure provide the funding required to support an affordability program. However, affordability provisions were included in the three bills which were introduced in the 116th Congress for long-term reauthorization of the NFIP: the National Flood Insurance Program Reauthorization Act of 2019 (H.R. 3167), and the National Flood Insurance Program Reauthorization and Reform Act of 2019 (S. 2187) and its companion bill in the House, H.R. 3872. As Congress considers a long-term reauthorization of the NFIP, a central question may be who should bear the costs of floodplain occupancy in the future and how to address the concerns of constituents facing increases in flood insurance premiums.” 

Implications for Homeowners and Mortgage Investors 

FEMA is clearly signaling that NFIP premium increases are coming. Any increases to insurance premiums will impact the value of affected homes in much the same way as rising interest rates. Both drive prices down by increasing monthly payments and thus reducing the purchasing power of would-be buyers. The difference, however, is that while interest rates affect the entire housing market, this change will be felt most acutely by owners of properties in FEMA’s Special Flood Hazard Areas that require insurance. The severity of these impacts will clearly be related to the magnitude of the premium increases, whether increase caps will be applied to properties as well as owners, and the manner in which these premiums get baked into sales prices. 

Mortgage risk holders need to be ready to assess their exposure to these flood zone properties and the areas that see the biggest rate jumps. The simplest way to do this is through HPI scenarios based on a consistent view of the ‘affordability’ of the house  i.e., by adjusting the maximum mortgage payment for a property downward to compensate for the premium increase and then solving for the drag on home price.


Get in touch with us for a no-obligation discussion on how to measure the impact of these forthcoming changes on your portfolio. We’d be interested in hearing your insights as well. 


Overcoming Data Limitations (and Inertia) to Factor Climate into Credit Risk Modeling

With each passing year, it is becoming increasingly clear to mortgage credit investors that climate change is emerging as a non-trivial risk factor that must be accounted for. Questions around how precisely to account for this risk, however, and who should ultimately bear it, remain unanswered. 

Current market dynamics further complicate these questionsLate last year, Politico published this special report laying out the issues surrounding climate risk as it relates to mortgage finance. Even though almost everyone agrees that underinsured natural disaster risk is a problem, the Politico report outlines several forces that make it difficult for anyone to do anything about it. The massive undertaking of bringing old flood zone maps up to date is just one exampleAs Politico puts it: 

The result, many current and former federal housing officials acknowledge, is a peculiar kind of stasis — a crisis that everyone sees coming but no one feels empowered to prevent, even as banks and investors grow far savvier about assessing climate risk. 

At some point, however, we will reach a tipping point – perhaps a particularly devastating event (or series of events) triggering significant losses. As homeowners, the GSEs, and other mortgage credit investors point fingers at one another (and inevitably at the federal government) a major policy update will become necessary to identify who ultimately bears the brunt of mispriced climate risk in the marketOnce quantified and properly assigned, the GSEs will price in climate risk in the same way they bake in other contributors to credit risk — via higher guarantee fees. For non-GSE (and CRT) loans, losses will continue to be borne by whoever holds the credit risk 

Recognizing that such an event may not be far off, the GSEs, their regulator, and everyone else with credit exposure are beginning to appreciate the importance of understanding the impact of climate events on mortgage performance. This is not easily inferred from the historical data record, however. And those assessing risk need to make informed assumptions about how historically observed impacts will change in the future. 

The first step in constructing these assumptions is to compile a robust historical dataset. To this end, RIskSpan began exploring the impact of certain hurricanes a few years ago. This initial analysis revealed a significant impact on short-term mortgage delinquency rates (not surprisingly), but less of an impact on default rates. In other words, affected borrowers encountered hardship but ultimately recovered. 

This research is preliminary, however, and more data will be necessary to build scenario assumptions as climate events become more severe and widespread. As more data covering more events—including wildfires—becomes available, RiskSpan is engaged in ongoing research to tease out the impact each of these events has on mortgage performance.  

It goes without saying that climate scenario assumptions need to be grounded in reality to be useful to credit investors. Because time-series data relationships are not always detectable using conventional means, especially when data is sparse, ware beginning to see promise in leveraging various machine learning techniques to this endWe believe this historical, machine-learning-based research will provide the backbone for an approach that merges historical effects of events with inputs about the increasing frequency and severity of these events as they become better understood and more quantifiable. 

Precise forecasting of severe climate events by zip code in any given year is not here yet. But an increasingly reliable framework for gauging the likely impact of these events on mortgage performance is on the horizon.  


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